CINE-BOOKS Privacy Policyfor Web Services and Applications

Last updated: Oct 20, 2016.

This Privacy Policy (“Policy”) describes our privacy practices with regard to your Personal Data. This Policy constitutes the integral part of the Agreement between you and the Company. All terms used in this Policy shall be understood and interpreted as set out in the Agreement. In particular, the Personal Data includes any data about you that specifically identifies you as an individual and information about your activities, such as information about your use of the Services, when directly linked to personally identifiable information (including automatically collected).

1Overview

PLEASE READ THIS POLICY CAREFULLY BEFORE USING THIS ENTERTAINMENT SERVICE.

The Company respects your privacy. This Policy describes the Personal Data we collect, how we use it, the purposes for which we share such Personal Data with others, and how you can contact us to ask any questions or express any concerns you may have about our privacy practices or the Personal Data that you have provided.

This Policy applies to the Personal Data collected through our Apps and the Website.

This Policy does not cover the collection and use of your Personal Data by our business partners, and does not cover any information that may relate to the Company outside of the Apps and the Website.

In addition, please review the Terms, which governs your use of the Service. BY USING OUR SERVICES, YOU CONSENT TO OUR POLICY AND TERMS AND OUR COLLECTION, USE AND SHARING OF YOUR PERSONAL DATA, AND OTHER ACTIVITIES, AS DESCRIBED BELOW.

2The Personal Data We Collect and How We Use It

We collect the personally identifiable data that you input into our Services and the data automatically generated by your use of our Services. We describe these two types of data below and explain how, alone or in combination with other data we collect, we use them.

2.1. The Personal Data You Input

A. Registration and Account information

You may input the Personal Data to make use of certain features of our Services. For example, when you create your CINE-BOOKS Account with us you will enter the Personal Data about yourself such as: email address, password, first name, last name, nickname, gender, country, birthday, social medial profiles, photo, etc.

Email. We may use your email address to send you Marketing Emails. You may opt out of receiving Marketing Emails through a link in such emails or by notifying our support team. Whether or not you opt out of such emails, we may use your email address to send you some Administrative Emails, which are necessary for us to duly provide the Services to you.

Birthday. We may use your birthdate to determine if you are qualified to create an Account with us or purchase certain Products or to understand the age distribution of our customers. If you receive our Marketing Emails, we may send you an annual “happy birthday” message that may also contain product offers.

Password. You shall be solely responsible for your password. We do not store it anywhere in our database.

B. Purchases

When purchasing the Cine-Book on our Website or the App you enter your payment method information to purchase the Products through your Account with us. Such payment method information (including billing information, credit card number, expiration dates, and security codes) is transferred to a third-party provider of payment services and is not retained by us.

When you purchase the Product offered in the Apps using your Account with a third party app store and platforms we do not collect the credit card information that you use for such purchases, and we are not responsible for the policies and practices of such app stores and platforms.

C. Social Networks

You can also engage with our content and other offerings on the Website and the Apps, such as gallery, videos, reviews and contests, on or through the Social Networks.

You may also choose to link your CINE-BOOKS Account to the Social Networks. When you link your Account or engage with our Products on or through the Social Networks, you may allow us to have ongoing access to certain Personal Data from your Social Networks accounts (e.g., name, e-mail address, profile photo, gender, birthday, location, your list of friends, people you follow and/or who follow you, the posts or the 'likes' you make). We may also receive other information (e.g., content viewed, book you like, information about advertisements within the content you have been shown or may have clicked on, etc.) from your Social Network interaction with various content.

By interacting with our Services through the Social Networks (including sharing or posting content from the Services to the Social Networks and vice versa, or by linking your Social Networks accounts with your CINE-BOOKS Account, inviting friends, etc.), you consent to the Company’s collection and use of your Social Networks information in accordance with this Policy.

You also agree and understand that by interacting with our Services through the Social Networks (for example, if you post information or content, such as by posting photos, commenting on a blog, or participating in other online activities at our Services, or when you interact with our Services through the Social Networks, plug-ins or other applications), this information may become public on the internet. Therefore, we cannot prevent further use of this information. You agree that the Social Networks are operated by themselves and are subject to their terms of use and privacy policies.

2.2. Information We Collect Automatically and How We Use It

Your use of our Services generates information that the Company collects automatically. This section summarizes the important types of information that we may collect which may relate to your personally identifiable information.

A. Technical and usage information

When you use our Website or the Apps certain non-personally identifiable information may be collected and used for analytical or statistical purpose by us or via third-party services (such as Google Analytics), such as the type of browser you are using (e.g., Firefox, Internet Explorer), the type of operating system you are using (e.g., Windows, Mac OS, iOS, and Android), the domain name of your Internet service provider or mobile carrier, IP address, and certain usage information.

B. Collection of mobile device data

When you use the Products through our Apps, certain non-personally identifiable information may be collected and used by us or any Analytical Tool (such as Flurry) in order to better understand our audience.

This information will enable us to keep a record of the Products that our users use, and to analyze general activity on our Services.

C. Content Selection

We may collect information about the Products that you purchase, place in your cart without purchasing, subscribe for, pre-order or browse. We may use that information to recommend to you Products that we believe might interest you.

D. Third Parties Acting on Our Behalf

We may use third party vendors to perform certain services on behalf of us, such as hosting the site or application, designing and/or operating the Service's features, tracking the Service's activities and analytics, and enabling the Company to send you special offers or performing other administrative services.

We may provide these vendors with access to user information, including device Identifiers and Personal Data, to carry out the services they are performing for you or for us. We may use third-party analytics service providers for purposes such as to evaluate and provide us with information about the Services and viewing of our Products.

These vendors may set and access their own Tracking Technologies (as described below) on your device and they may otherwise collect or have access to information about you. Please recognize that the Company and/or its vendors (such as mailing houses or customer service vendors) may store this information, and may share this information with third parties as necessary to process your transactions and provide access to the Services by you and your Subaccount holders. the Company may also use this information for internal review and analysis of the Services, the customer service process, and consumer comments.

E. Tracking Technologies including Cookies

We use, and allow third parties to use, various new and hereafter Tracking Technologies. This may include information about whether you accessed our Services, what pages or views you accessed, how long you stayed on each page or view, any links you clicked on while on the Service, the website or other property you came from, what Products you browsed, placed in your cart, downloaded, or purchased, as well as the hardware, software, and network data discussed in the preceding section.

Such Tracking Technologies may include cookies, pixel tags, also referred to as web beacons (pieces of data embedded in an image on a website or email that allow for tracking of your activity on a website or your actions with regard to an email, such as whether you opened the email or accessed a link within the email), and anonymous identifiers (text strings that function like cookies, but used on mobile devices or other platforms that do not accommodate cookies).

Cookies are small data files that are commonly stored on your device when you browse and use websites and online services. They are widely used to make websites work, or to work more efficiently, as well as to provide reporting information and assist with service or advertising personalization. It can include pieces of data embedded in an image on a website or email that allow for tracking of your activity on a website or your actions with regard to an email, such as whether you opened the email or accessed a link within the email) etc.

The categories of cookies we use are:

Strictly necessary cookies – enable you to move around the Services; for example, help to remember you are logged into your account;

Performance cookies – collect anonymous information about how you use the Services to enable us to improve how the they operate;

Functionality cookies – allow the Services to remember your user name, language, and the region you are located or other information to provide you with an experience more appropriate with your selections;

Targeting and advertising cookies – allows the Services to collect information about your browsing habits and deliver advertisements that are more relevant to your interests. That information is shared with other parties such as advertisers.

Generally, Internet browsers contain controls for managing cookies. Those controls may enable you to delete cookies or to accept or reject certain categories of cookies. If you reject or delete cookies, the performance of the related features and functions of our Website may be impaired to you.

You shall specifically agree to our use of cookies and Web beacons when you use our Website by clicking the respective button in the notification.

We, or third parties with our permission, may use Tracking Technologies in the following ways:

To manage our business and improve our Service based on factors such as how many users visit or use our Service, what pages and views are accessed, whether visitors are new or repeat visitors, which features and Content of our Service most interest our visitors, and how our Service performs from a technical point of view (such as the speed with which content loads and the incidence of technical problems).

To provide personalized recommendations, Content, advertising, marketing emails, and guidance on Service features based on your activity on our Service, such as prior purchases, abandoned shopping cart selections, and browsing activities.

To remember actions you took to avoid asking you to repeat them during a session or to provide features such as enabling you to resume reading at the last page you accessed, synchronized across devices.

To enable us or third party sites or services or advertising companies to collect and store information regarding your activity on the App, the Website, our other services, or third party services to provide you with personalized recommendations or content or to provide you or broader advertising or to measure the effectiveness of marketing campaigns. The third party advertisers may serve advertisements for us or for other companies on the App, the Site, our other services, or on third party services.

To measure and analyze activity on the App, the Website, our other services, or third party services. In addition to the uses outlined above, we or any provider of such measurement and analytical services may provide non-personally identifiable data to third parties.

F. Remarketing on Our Site

We may use Google remarketing services, which allow third parties, including Google, to serve advertisements to you on our behalf based on your activity on our Website. This assume placing pages of our Website a small piece of code provided by Google. This code enables third parties, including Google, to place a cookie on your computer that tells them about your visit to our Website and which content you have browse. That allows them display relevant advertisements when you visit other websites within the Google Display Network. We may also use similar remarketing services from other companies.

3General Use of Personal Data

We use the Personal Data we collect to provide, analyze, administer, enhance and personalize our services and marketing efforts, to process your registration, your orders and your payments, and to communicate with you on these and other topics. Collection and use of your Personal Data is performed by the Company for the following purposes:

Creation, management and maintenance of an Account;

Processing of your inquiries and operations at the Services, Customer service;

Analyzing and understanding our audience for the purposes of improving our service, offered Content and technologies (including our user interface experiences); improving of delivery optimization, content selection, and other parts of the Services;

Communicating with you concerning our service (for example by email or push notifications);

To assist third party services acting on our behalf;

Other purposes.

4Personal Data We Share and Disclose

We may share your Personal Data with the following, or under any of the following (without limitation) purposes:

Our corporate affiliates such as a corporate subsidiary or other companies whose practices are not covered by this Policy.

Our current or prospective business partners, including investors, studios, authors and publishers who are interested in providing Digital Content for any part of our Service, (a) who have a need to understand the nature and operation of our business, such as sales and usage trends or sales data underlying royalty calculations (information provided in this respect is not personally identifiable), or (b) if through our Services or their services you have requested a product or service that requires us to transfer the information (for example, voting for the cine-books or pre-orders).

Third parties we have retained to perform services on our behalf, such as Digital Content hosting and delivery, data analytics, marketing and advertising, and payment services.

Sale of assets or change of control. In the event of a sale of assets or change in ownership, we may transfer such information to a successor of the Company or any person or entity that acquires ownership or control of the Company or the Services via any means.

Legal and law enforcement purposes. We may disclose personally identifiable information in response to legal process, for example (a) in response to a court order or a subpoena, or in response to a law enforcement agency's request, if it is in writing, reasoned and occasional and if it is made within their official mission, (b) to protect the rights or welfare of others, including our employees and owners of copyright or other intellectual property in Products or Digital Content.

We also may disclose such information to third parties in connection with fraud-scoring, detection, and prevention activities or where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our terms of use, to protect our rights under our contracts, terms of service, and to otherwise protect our rights and the rights of others, and as otherwise required by law.

Service providers. Our agents and contractors may have access to personally identifiable information to help carry out the services they are performing for us.

Promotional offers: We may offer joint promotions or programs () that, in order for your participation, will require us to share your information with third parties. In fulfilling these types of promotions, the third parties may obtain personally identifiable information that visitors voluntarily submit to participate in the activity. We will notify you at the time your personally identifiable information is requested whether such information will be shared with these parties. Please note that these third parties are responsible for their own privacy practices. We have no control over these third parties' use of this information.

5Additional Information Regarding Children's Privacy

We do not collect, use or share the Personal Data of children (under 18 years old). As mentioned in our Terms, you must be legal adult to access to the CINE-BOOKS Services under the applicable law and the law of the country where you are located.

6Security

We believe we use reasonable administrative, logical, physical and managerial measures to safeguard your Personal Data against loss, theft and unauthorized access, use and modification. However, we cannot assure you that personally identifiable information that we collect will never be used or disclosed in a manner that is inconsistent with this Policy. You should understand that no feasible system of data security is invulnerable. Accordingly, we cannot guarantee the 100% security of your information.

7Links to Other Websites and Services

The CINE-BOOKS Services may be provided through platforms and content distributors, or contain links to websites operated by third parties whose policies regarding the handling of information may differ from ours. For example, you may be able to access the CINE-BOOKS Services through platforms such as Apple App Store, Google Play, Amazon App Store, third-party content providers, various devices, such as smart TVs, mobile devices, and a number of other Internet connected devices and platforms. Those websites and platforms are not under our control. They have separate and independent privacy or data policies, privacy statements, notices and terms of use, which we recommend you read carefully. We are not responsible for those third party privacy policies or the related data processing practices.

8How You Can Access Or Correct Personal Data

The Personal Data you provided us through the Services can be reviewed and edited in the section «-Main Menu — Profile» or you may contact our support team.

You may not be able to remove or edit any reviews, comments and other postings you made through our Services by yourself.

In case if you have a valid reason to remove some kind of publication or any Personal Data, including your Account,- please contact our support team, indicating the information you want to edit or remove. The information, in particular, your Personal Data that we remove is not stored by the Company.

9Changes to This Privacy Statement

From time to time, we may update this Policy. If the changes are material, we may notify you by posting or displaying a notice on this page, by email, on an updated App available for free download, or by any other method we choose at our discretion. You should review this Policy regularly while you are connected to the Internet so that you are aware of the most current rights and obligations relating to use of the Service. It is your responsibility to check our website periodically for changes. Your continued use of the CINE-BOOKS service after any such updates take effect will constitute acceptance of those changes.

If you do not accept changes to this Policy, you may cancel your use of the CINE-BOOKS Services. To see when this Privacy was last updated, please see the "Last Updated" section above.

10Geography

We store the Personal Data that we hold about you in the European Union (“EU"). Any Personal Data gathered by the Company in connection with our Services may be transferred to, processed and stored in countries where data protection laws may be less protective than the legislation where you live. This may happen when facilities belonging to the Company are located in a country outside of the European Economic Area or in a country which is not the party to the Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data (1981).

Supplying the Company with the Personal Data, you permit its transfer outside the country within the bounds of such use. When a transfer to non-European countries happens, we ensure that it takes place in accordance with this Policy and applicable laws.

11Contact Information

The Services are offered by the Company. If you have any questions regarding the use of Services or regarding this Policy, you should contact our support team.